United States General Accounting Office
GAO Report to the Honorable
James M. Inhofe, U.S. Senate
February 2000
STRUCTURED
SETTLEMENTS
The Department of
Justice’s Selection
and Use of Annuity
Brokers
GAO/GGD-00-45
United States General Accounting Office General Government Division
Washington, D.C. 20548
B-283058
February 16, 2000
The Honorable James M. Inhofe
United States Senate
Dear Senator Inhofe:
The federal government solicits the services of private brokers to assist in
structuring settlements with claimants in lawsuits against federal agencies.
Because private brokers can earn lucrative commissions from insurance
companies, it is important that the Department of Justice (DOJ) has
criteria and a system of controls to promote fairness and avoid the
appearance of favoritism in selecting these brokers. This report responds
to your request that we review DOJ’s policy and guidance for selecting
structured settlement brokers. As agreed with your office, this report (1)
discusses the policies and guidance for selecting structured settlement
1
brokers used by DOJ and six selected agencies and (2) provides a list of
the structured settlement brokerage companies used by DOJ and the
number of settlements awarded to each company since May 1997.
In 1993 and 1997, DOJ issued policies and guidance on the selection of
Results in Brief structured settlement brokers to promote fairness and to avoid the
appearance of favoritism. DOJ officials told us that its policies and
guidelines permit some discretion and that when selecting a particular
broker, they generally relied on such factors as reputation, past
experience, knowledge, and location. However, DOJ officials also told us
they were unable to specify reasons why attorneys selected particular
brokers to settle specific cases, because DOJ did not require
2
documentation of these decisions. Without an internal control requiring
that the reasons for selecting a particular settlement broker be
documented and readily available for examination, it is more difficult to
verify that selection policies and guidelines were followed and, in turn, to
avoid the appearance of favoritism and preferential treatment.
Overall, the six federal agencies we surveyed described policies and
guidance in selecting structured settlement brokers that were similar to
1
The six selected agencies were the Departments of Health and Human Services (HHS) and Veterans
Affairs (VA); the Air Force, Army, and Navy; and the United States Postal Service.
2
The Comptroller General’s Standards for Internal Control in the Federal Government (GAO/AIMD-00-
21.3.1) requires that all transactions and significant events are to be clearly documented and that the
documentation is to be readily available for examination.
Page 1 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
DOJ’s. Also, like DOJ, none of the agencies had internal controls requiring
their attorneys to document their reasons for selecting a specific broker.
One agency had a written supplemental policy governing the use of
structured settlements, but it did not require documentation of decisions.
Officials at the other five federal agencies said they also generally relied on
such factors as reputation, past experience, knowledge, and location for
selecting a particular structured settlement broker. However, as was the
case with DOJ, the reasons why particular brokers were selected for
specific cases were not documented.
Our review of the list of structured settlement brokerage companies used
by DOJ and the number of settlements assigned to each company showed
that DOJ selected a few companies to handle most of its structured
3
settlement business. According to DOJ, the companies frequently have
multiple offices and brokers that compete with each other within the same
company. Thus, a simple count of the number of companies could be
misleading. Although DOJ used 27 different structured settlement
companies to settle 242 claims for about $236 million between May 1, 1997,
and May 1, 1999, 70 percent (169 cases) were awarded to 4 brokerage
companies. Of the remaining 23 companies, none were awarded more than
17 cases each.
We are recommending that DOJ (1) establish internal controls that require
its officials to document the reasons for selecting a particular broker or
brokerage company to settle a case and (2) disseminate this guidance to
federal agencies responsible for handling structured settlement claims.
A structured settlement is the payment of money for a personal injury
Background claim in which at least part of the settlement calls for future payment. The
payments may be scheduled for any length of time, even as long as the
claimant’s lifetime, and may consist of installment payments and/or future
lump sums. Payments can be in fixed amounts, or they can vary. The
schedule is structured to meet the financial needs of the claimant.
4
For years, structured settlements have been widely used in the tort area to
compensate severely injured, often profoundly disabled, tort victims.
Cases generally involve medical malpractice and other personal injury. The
5
Federal Tort Claims Act (FTCA) is the statute by which the United States
3
Thirteen of the 94 U.S. Attorneys offices did not provide structured settlement data.
4
A tort is a civil wrong, not including a breach of contract, for which the injured party is entitled to
damages.
5
28 U.S.C. §§1346(b), 2671-2680.
Page 2 GAO/GGD-00-45 Selection and Use of Annuity Brokers
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6
authorizes tort suits to be brought against itself. With certain exceptions,
it makes the United States liable for injuries caused by the negligent or
wrongful act or omission of any federal employee acting within the scope
of his or her employment, in accordance with the law of the state where
the act or omission occurred. Generally, a tort claim against the United
States is barred unless it is presented in writing to the appropriate federal
agency within 2 years after the claim accrues.
In addition, the National Childhood Vaccine Injury Act of 1986, as
amended, created a mechanism for compensating persons injured by
certain pharmaceutical products. The act established the National Vaccine
7
Injury Compensation Program (VICP) as an alternative to traditional
product liability and/or medical malpractice litigation for persons injured
by their receipt of one or more of the standard childhood vaccines
8
required for admission to schools and by certain employers. VICP is “no-
fault.” That is, claimants need not establish that the vaccine was defective,
or that any degree of negligence was involved in its administration. The
only liability-related question is causation—did the vaccine cause the
injury for which compensation is sought?
The industry standard of practice requires the use of a licensed broker or
9
insurance agent to obtain a settlement annuity. DOJ’s Civil Division
estimated that structured settlements constitute between 1 and 2 percent
of all settlements in litigated tort cases. Brokers receive no direct
compensation from the government; rather, they are compensated by the
insurance company from whom the annuity is purchased. The insurance
company typically pays the brokers’ commissions, which amount to 3 or 4
percent of the annuity premium. The government attorney negotiating the
case is responsible for selecting the broker.
6
Three major exceptions under which the United States may not be held liable, even in circumstances
where a private person could be held liable under state law, are the Feres doctrine, which prohibits
suits by military personnel for injuries sustained incident to service; the discretionary function
exception, which immunizes the United States for acts or omissions of its employees that involve
policy judgments; and the intentional tort exception, which precludes suits against the United States
for assault and battery, and certain other intentional torts, unless they are committed by federal law
enforcement or investigative officials.
7
42 U.S.C. §§ 300aa-10 et seq.
8
Currently, the vaccines covered under the Program are those administered to protect against
diphtheria, tetanus, pertussis (whooping cough), measles, mumps, rubella (German measles), polio,
hepatitis B, varicella (chicken pox), Haemophilus influenzae type b, and rotavirus.
9
The responsibilities of DOJ’s Civil Division include representing the United States, its agencies, and its
employees in suits where monetary judgments are sought for damages resulting from negligent or
wrongful acts.
Page 3 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
Structured settlements for the federal government are negotiated by the
Civil Division’s torts attorneys, Assistant United States Attorneys (AUSAs),
or agency attorneys. AUSAs are authorized to settle certain cases. An
agency may not settle a tort claim for more than $25,000 without the prior
written approval of the Attorney General or her designee, unless the
Attorney General has delegated to the head of the agency the authority to
10
do so.
To ascertain DOJ’s policies and guidance for the selection of settlement
Objectives, Scope, and brokers, we reviewed the Torts Branch handbook, Damages Under the
Methodology Federal Tort Claim Act (section V: Settlements), and other relevant
documents pertaining to broker selection policies. In addition, to obtain
information about the procedures used to select brokers, we interviewed
attorneys in DOJ’s Civil Division and representatives from the Executive
Office for United States Attorneys (EOUSA).
To obtain information on broker selection policies and guidance used by
federal agencies, we asked DOJ to identify other federal agencies that
handled structured settlement claims. DOJ identified six agencies—HHS
and VA; the Air Force, Army, and Navy; and the U.S. Postal Service. At
each of the six agencies, we met with officials who were responsible for
negotiating structured settlement claims. We discussed their policies and
procedures for selecting structured settlement brokers and asked them
what factors they considered during the selection process. In addition, we
obtained and reviewed a copy of the Army’s standard operating
procedures pertaining to structured settlements. Also, we asked the six
agencies to supply information pertaining to the number of structured
settlements since May 1997.
To provide the list of DOJ’s structured settlement annuities between May
1, 1997, and May 1, 1999, we used data DOJ collected from the Civil
Division and the United States Attorneys Offices. The Civil Division’s data
came from the Torts Branch, which routinely handles structured
settlements. The United States Attorneys’ data were collected by EOUSA
and include all the data received by EOUSA as of August 12, 1999. As of
that date, 34 of the 94 United States Attorneys offices had reported annuity
11
settlements during the relevant time period. We did not verify the
accuracy of the information collected from the Torts Branch or EOUSA.
10
For example, the Attorney General has delegated the authority to settle tort claims of up to $200,000
to the Secretary of Defense.
11
Thirteen offices did not respond to EOUSA’s request for information.
Page 4 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
To gain a broader understanding of structured settlements, we met with
the Executive Vice President of the National Structured Settlement Trade
12
Association (NSSTA). We obtained information concerning brokers
working with federal structured settlements.
We did our audit work between June and December 1999 in accordance
with generally accepted government auditing standards. We requested
comments on a draft of this report from the United States Attorney
General or her designee. Also, in January we discussed the contents of
this report with VA’s Assistant General Counsel; U.S. Postal Service’
Claims Division Counsel; and the Army’s Torts Claims Division Chief.
Also, we obtain comments for the Air Force and Navy from DoD’s Senior
Report Analysis for the GAO Affairs Directorate. In addition, we spoke
with HHS’ Associate General Counsel. The written and oral comments we
received are discussed near the end of the report.
Although DOJ had established policies and guidance for the selection of
Federal Policies for structured settlement brokers, the policies and guidance did not include an
Selecting Structured internal control requiring attorneys to document their reasons for selecting
Settlement Brokers a specific broker. Similarly, although the six agencies we reviewed said
they generally followed DOJ’s policy guidance for selecting a structured
Lacked Adequate settlement broker, they were not required to document their reasons for
Internal Control selecting a particular broker. None of these agencies documented the
reasons why they selected particular brokers.
DOJ Did Not Document DOJ had established policies and guidance governing the selection of
structured settlement brokers, but it did not require that the reasons for
Reasons for Selecting selecting a specific broker be documented. On July 16, 1993, the Director
Brokers of the Civil Division’s Torts Branch, which is responsible for FTCA claims
and litigation, issued a memorandum that was intended to supplement the
guidance on structured settlements in the Damages Handbook and to
codify previous informal guidance on the selection of structured
settlement brokers. Neither the Damages Handbook nor the memorandum
addressed documenting the reasons for selecting a specific broker.
On June 30, 1997, the Acting Associate Attorney General expanded the
policy guidance by issuing a memorandum to United States Attorneys.
However, the new guidance did not address documenting the reasons for
12
NSSTA is an organization composed of more than 500 members who negotiate and fund structured
settlements of tort and worker’s compensation claims involving persons with serious, long-term
physical injuries. Founded in 1986, NSSTA’s stated mission is to advance the use of structured
settlements as a means of resolving physical injury claims.
Page 5 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
broker selections. Generally, the 1997 policy guidance outlined procedures
concerning the selection of structured settlement brokers. These included:
• Every broker was to be given an opportunity to promote its services.
• No lists of “approved,” “preferred,” or “disapproved” brokers were to be
maintained.
• Brokers who performed well in the past were to be appropriately
considered for repeated use: however, such use could not be to the
exclusion of new brokers.
• Attorneys were expected to look to supervisory attorneys for assistance;
however, final broker selection was the responsibility of the attorney
negotiating the settlement.
• When a structured settlement in an FTCA case included a reversionary
13
interest in favor of the United States, the Torts Branch’s FTCA staff was
to be consulted to maintain appropriate records and ensure consistency.
• Any activity tending toward an appearance of favoritism, any action
contrary to any of the above rules, or any activity incongruent with the
spirit of the memorandum was to be scrupulously avoided.
According to agency officials, attorneys sometimes asked each other about
their experiences with a particular broker, but the attorney negotiating the
case is responsible for making the final broker selection, and is not
required to consult with the FTCA staff. DOJ officials told us that in the
absence of a requirement to do so, they did not document the reasons for
selecting particular settlement brokers.
The Comptroller General’s guidance on internal controls in the federal
government, Standards for Internal Control in the Federal Government
(GAO/AIMD-00-21.3.1), requires that all transactions and significant events
are to be clearly documented and that the documentation is to be readily
available for examination. The documentation should appear in
management directives, administrative policies, or operating manuals and
may be in paper or electronic form. All documentation and records should
be properly managed and maintained.
13
Reversionary interest is the interest that a person has in the reversion of lands or other property.
Page 6 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
14
Selected Agencies Did Not During 1999, DOJ provided its policy guidance to the six selected
agencies in our review—HHS and VA; the Air Force, Army, and Navy; and
Document Reasons for the Postal Service. Generally, the selection processes the agencies said
Selecting Brokers they had were similar to DOJ’s, (e.g., the attorney negotiating a case made
the final decision, no list of approved or disapproved structured settlement
brokers was maintained).
Five agencies in our review identified various factors they considered
when selecting a structured settlement broker. For example:
• HHS, Postal Service, and VA officials told us that they tended to select
brokers with offices in the Washington, D.C., area. According to VA
officials, the use of distantly located brokers created problems because of
(1) differences in time zones and (2) the inability of nonlocal brokers to
physically conduct work on short notice.
• Air Force, Navy, and VA officials told us that they put considerable weight
on an impressive presentation given by the broker’s firm.
• HHS, Navy, Postal Service, and VA officials said they looked at the broker’s
knowledge and experience in handling structured settlement cases for the
federal government and based their selections on positive past
experiences.
• Navy and Postal Service officials said they looked for brokers with a
reputation for being dependable and responsible.
In addition, the Army had established supplemental policies governing the
selection of structured settlement brokers. According to the Army’s
standard operating procedures, brokers were to be selected on a case-by-
case basis according to the following criteria: (1) the broker’s ability to
become a member of the negotiating team, participate in negotiations, and
travel at his or her own expense; (2) the selecting administrative officer’s
previous interviews with or knowledge of the broker; (3) the broker’s
ability to present his views verbally (if the case requires in-person
negotiations); and (4) the broker’s experience if the administrative officer
is inexperienced. In certain more specialized cases, the selecting
administrative officer’s choice of a specific broker must be approved by a
higher authority.
14
This guidance was contained in a June 30, 1997, memorandum from the Acting Associate Attorney
General to the United States Attorneys regarding the selection of structured settlement brokers.
Page 7 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
Even though federal agencies we surveyed said they provided policy
guidance on broker selection, none of them required documentation of the
reasons for selecting a structured settlement broker. In the absence of this
requirement, none documented the reason for selection.
DOJ has selected several structured settlement brokerage companies to
DOJ Selected a Few handle most of the structured settlement claims. Between May 1, 1997,
Brokers to Handle and May 1, 1999, DOJ used 27 different structured settlement brokerage
Most Settlements companies to settle 242 claims for $236 million. (See table 1 for the
number and total annuity costs of annuity settlements handled by
Claims brokers.) Of the 242 claims awarded, 70 percent (169 cases) were awarded
to 4 brokerage companies. One of the four companies was awarded 30
percent (72 cases) of the total number of cases. The remaining 23
companies were awarded 30 percent of the total number of cases.
Table 1: Annuity Settlements for DOJ a
(May1997 to May 1999) Brokerage Number of settlements Total annuity cost
AIG Life Insurance Company 1 $97,000
Allstate Life Insurance Company 1 99,333
Brant Hickey & Associates 10 4,894,998
Canada Life Assurance
Company 1 100,000
Creative Settlement Consultants 8 8,249,758
Delta Group 26 33,800,720
Garrett Wong & Associates 1 1,000,000
GE Capital Assurance 1 150,000
Halpern Group 1 484,505
Huver & Associates, Inc. 7 3,550,800
JMW Settlements, Inc. 35 29,235,685
Joe Huver, Amicus Group 3 760,000
Kenneth H. Wells & Associates 1 16,430
Legal Economic Evaluations, Inc. 1 156,500
Minet Settlement Services, Inc. 1 171,719
Near North Financial Group 2 406,946
Near North Insurance Brokerage,
Inc. 2 700,129
Pension Company 2 1,351,381
Ringler Associates, Inc. 36 24,039,764
Settlement Associates, Inc. 17 21,691,697
Settlement Planning Associates 5 3,339,803
Settlement Professionals, Inc. 1 500,000
Sheerin Corporation 2 689,810
Structured Financial Associates 72 99,283,574
Page 8 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
Structured Funding Group 2 600,000
Structured Settlement Company 2 380,000
Summit Settlement Services 1 250,000
Total 242 $236,000,552
Note 1: DOJ settlements may Include annuity settlements for the Torts Branch, Civil Division and the
U.S. Attorney Offices.
Note 2: Thirteen U.S. Attorney offices did not provide structured settlement data.
a
Includes four insurance carriers (AIG Life Insurance Company, Allstate Life Insurance Company, GE
Capital Assurance, and Canada Life Assurance Company) because the name of the structured
settlement broker was not included in the data.
Source: DOJ data.
Because DOJ did not document the reasons for selecting a particular
broker, DOJ officials could not specifically say why certain companies
received more business than others. However, as noted previously, DOJ
officials cited a variety of reasons for selecting a specific structured
settlement broker, such as experience, dependability, and knowledge of
federal structured claims.
According to DOJ, the companies frequently have multiple offices and
brokers that compete with each other within the same company. Thus, a
simple count of the number of companies could be misleading.
DOJ has developed policies and guidance for selecting structured
Conclusions settlement brokers and disseminated this information to the six other
federal agencies with authority to handle structured settlement claims that
we contacted. However, the policies and guidance lacked an internal
control requiring that the reasons for selecting a broker be documented
and readily available for examination. This is important because without
documentation of transactions or other significant events, DOJ can not be
certain that its policies and guidance on selecting structured settlement
brokers are being followed. Further, without documentation on the
reasons settlement brokers were selected, it is more difficult to avoid the
appearance of favoritism and preferential treatment in a situation where
some brokers get significantly more business than others.
We recommend that the Attorney General of the United States direct the
Recommendations Director of the Torts Branch responsible for FTCA claims and litigation,
Civil Division, to
• develop an adequate internal control to ensure that the reasons for
selecting structured settlement brokers are always fully documented and
readily available for examination; and
• disseminate this guidance to federal agencies, including those in our
survey, responsible for handling structured settlement claims.
Page 9 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
We requested comments on a draft of this report from the Attorney
Agency Comments General or her designee. On January 18, 2000, the Acting Assistant
Attorney General, Civil Division provided us with written comments,
which are printed in full in appendix I. The Justice Department expressed
appreciation that the report “outlines the many steps undertaken by the
Department to ensure fairness in the broker selection process.”
DOJ said its existing policies and guidance to ensure that the selection of
brokers is fair are effective. Therefore, it disagreed with our
recommendation that DOJ implement an adequate internal control to
ensure that the reasons for selecting a specific structured settlement
broker are always fully documented and readily available for examination.
DOJ noted that the Comptroller General’s Standards for Internal Control in
the Federal Government specify that management should design and
implement internal controls based on the related costs and benefits. It
stated that it was DOJ’s belief that the costs of implementing the
recommendation, in terms of diversion of attention from substantive
issues and generation of extra paperwork, would substantially outweigh
any benefits.
We recognize that determining whether to implement a particular internal
control involves a judgment about whether the benefits outweigh the
costs. We believe that the benefits of implementing our recommendation
would outweigh any associated costs and paperwork. As stated in this
report, these benefits are twofold: requiring documentation would help
enable DOJ to (1) determine if its policies and guidance on selecting
brokers are being followed and (2) protect DOJ from charges of favoritism
towards a specific broker or brokers. Further, noting the reasons for
selecting a specific broker in the case file at the time the selection is made
would appear to require only minimal paperwork or cost. For example, a
concise memo to the file stating the rationale for the selection would
suffice.
DOJ also expressed concern that, although we observed that most
structured settlements have been awarded to a relatively small number of
companies, we did not mention that many of the selected companies had
multiple offices and brokers that competed for the same work. According
to DOJ, by “treating as a monolith all brokers affiliated with the major
companies, the draft report ignores the actual way those businesses are
run and runs the risk of significantly understating the actual number of
brokers competing to handle DOJ structured settlements.”
Page 10 GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058
In response, we have noted that according to DOJ, because structured
settlement companies may have multiple offices and brokers, the number
of companies could be misleading. Data were not readily available for us
to determine the extent to which multiple brokers within a single company
competed for the same settlement. Nevertheless, the number and cost of
settlements by brokerage company show that DOJ placed the majority of
its settlement work with a relatively small number of companies—a
situation that still could open it up to charges of favoritism towards these
companies.
Cognizant officials at HHS, VA, Air Force, Army, Navy, and the Postal
Service said they generally agreed with the information presented in the
report. The Army provided additional information to clarify its policy for
selecting structured settlement brokers, and we incorporated this
information in the report where appropriate.
We are sending copies of this report to Senator Orrin G Hatch, Chairman,
and Senator Patrick J. Leahy, Ranking Minority Member, Senate
Committee on the Judiciary; Representative Henry J. Hyde, Chairman, and
Representative John Conyers, Jr., Ranking Minority Member, House
Committee on the Judiciary; and the Honorable Janet Reno, the Attorney
General. We are also sending copies to other interested congressional
parties. Copies will also be made available to others upon request.
If you or your staff have any questions, please call me or Weldon McPhail
on (202) 512- 8777. Key contributors to this assignment were Mary Hall and
Jan Montgomery.
Sincerely yours,
Richard M. Stana
Associate Director, Administration
of Justice Issues
Page 11 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Contents
Letter 1
Appendix 14
Comments From the
Department of Justice
Tables Table 1: Annuity Settlements for DOJ (May1997 to May 8
1999)
Abbreviations
AUSA Assistant United States Attorney
DOJ Department of Justice
EOUSA Executive Office for United States Attorneys
FTCA Federal Tort Claims Act
HHS Department of Health and Human Services
NSSTA National Structured Settlement Association
VA Department of Veterans Affairs
VICP National Vaccine Injury Compensation Program
Page 12 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Page 13 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Appendix
Comments From the Department of Justice
Page 14 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Appendix
Comments From the Department of Justice
Page 15 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Appendix
Comments From the Department of Justice
Page 16 GAO/GGD-00-45 Selection and Use of Annuity Brokers
Page 17 GAO/GGD-00-45 Selection and Use of Annuity Brokers
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